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Save Face Standards For Accreditation Final Nov 2017 PDF
Save Face Standards For Accreditation Final Nov 2017 PDF
Introduction Page(s) 3
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Practitioners who perform non-surgical cosmetic interventions and the premises from
which they operate will be assessed against a rigorous set of standards that measure the
performance and suitability required to achieve Save Face Accreditation.
The standards will help to drive continuous improvement in the quality of services
provided and the suitability of the environments in which the treatments take place, to
safeguard the public from un-due risk and harm.
The Save Face Standards reference Legislation, Regulation, Professional Standards and best
practice standards. Public and practitioner safety and good customer care underpin each of
them.
Only regulated health care professionals may apply for accreditation. Though our Standards
reflect our accreditation process (Those Standards we can verify either by documentary evidence
submitted, or with site inspection and practitioner/staff interviews), the expectation that registrants
will maintain the standards required by their regulatory bodies is explicit and Save Face will hold
registrants accountable to these standards in addition to The Save Face Standards included in
this document.
Our register signposts risk averse consumers to professional, safe and ethical non- surgical
cosmetic treatment providers. Applicants for accreditation should see the standards and process
as a means to verify their practice does indeed meet best practice standards, or as a tool to
support them to identify and manage risks in order to meet the Standards.
We provide useful resources to minimize any additional administrative burden, in the form of
template policies and procedure protocols, patient information, consent forms, guidance
documents and references to signpost background and promote knowledge.
The process is designed to be constructive and supportive. Applicants are assigned a dedicated
support agent to provide assistance and guidance.
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Accreditation will be applicable to both practitioners and premises.
Accreditation is not an end point. It drives continuous improvement through on-going assessment
against standards to identify improvement areas and take remedial actions.
All applicants will need to complete the following two stage process to become accredited.
All applicants seeking accreditation or re-accreditation will have to attest to meeting eligibility
criteria for accreditation, providing factual evidence and documentation in relation to qualification,
training, indemnification and clinical and safety protocols. The evidence will be submitted online
and will be assessed to determine the readiness of the practitioner/ premises operator an on-site
assessment visit.
The assessment will comprise of a site inspection and an interview with the practitioner. The site
inspection will ensure that the premises is compliant with all relevant regulatory and legislative
requirements and that all relevant policies, procedure and risk assessments are appropriately
and effectively implemented. The interview will not be an assessment of clinical expertise, but of
the entire consumer experience, assessing the application of a wide range of processes, policies
and procedure, including but not limited to; consultation and consent processes, medicines
management, medical records management and aftercare.
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To ensure a thorough and fair assessment of applicants against the Save Face Standards is
achieved, there will be four key methods of evaluation which will be used to assess whether a
practitioner/ premises operators meets the minimum requirements for accreditation. There are
four key methods of evaluation, each standard will be marked with the relevant process for
evaluation and assessment.
The method of assessment for the standards set out in this document have been colour coded
as illustrated below to demonstrate which assessment method will be utilized for each
standard and at which part of the process it will be checked.
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Additional & Ongoing Methods of Assessment
Self Assessment
Applicants will be required to self-assess their services and performance against the applicable
standards, by proceeding with the accreditation process they are undertaking that they meet the
applicable minimum requirements and will conduct all relevant activity in strict accordance with the
Save Face standards.
Customer satisfaction surveys measure the degree to which customer expectations of a service are
met or exceeded. Customer feedback will be used to measure the standards that are most likely to
impact on the customer experience. All feedback will be documented and monitored throughout the
period of accreditation and will be used as a valuable tool for quality improvement for re-
accreditation assessments.
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Standard A1 Practitioners
A1.1 The practitioner providing treatment and care holds current registration with and is accountable to a
A1.2 The practitioner practices in accordance with the professional conduct and standards required by
their statutory body.
A1.3 Any sanctions or complaints published by either the Statutory Registers, The CQC or The ASA will be
signposted on the practitioner’s profile if current (within 6 months of accreditation). The reference will
be removed when the sanction is lifted or no longer applies.
Doctors General Medical Council (GMC) Good Medical Practice
Dentists The General Dental Council (GDC) Standards for The Dental Team 2013
Further, Save Face recognizes and holds all registrants accountable to the
Where Save Face has directly referenced GMC guidance, this is indicated by the number of the GMC
A1.4 Employers maintain systems to verify registration with the appropriate statutory register, including
that of outsourced or temporary practitioners.
A1.5 Where a company employs practitioners who are not registered healthcare professionals, their title
should reflect this. Titles for these employees should not include the word, ’medical’, and should be
as transparent as possible.
A1.6 Information on the qualifications (nurse/midwife, doctor, dentist, prescribing pharmacist) of the
practitioner, including their full name as it appears on the statutory register, should be published on
the business website where one exists, and/ or available in the clinic literature. Published information
must be factual and honest. The title, ’Dr.” may only be used by those who are registered with The
GMC and by Dentists with post nominals BDS included.
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Standard A2 Competency
A2.1 A practitioner must recognize and work within the limits of their competence and refer a patient to
another practitioner where they cannot safely meet their needs. (1)
A2.2 Keeps knowledge and skills up to date.
A2.3 The practitioner must evidence treatment specific training in all the procedures they undertake.
A2.4 The practitioner must evidence a minimum of 15 hours learning activities relevant to their non-surgical
cosmetic practice annually; which must include a mandatory basic life support update. (3)
A2.5 The practitioner must evidence a minimum of 150 hours' clinical practice per year, directly related to
non-surgical cosmetic procedures. New registrants unable to evidence hours will be mentored and
should aim to achieve this standard within 3 years.
A2.6 Non- prescribing practitioners must evidence protocols for appropriate supervision and delegation in
accordance with The Medicines Act 1968 and Standards required by their statutory body.
A2.7 The practitioner must submit verifiable feedback from a minimum of five patients.
A2.8 The Practitioner must publish and promote means for patients to provide independently verifiable
feedback.
A2.9 The practitioner must evidence compliance with their statutory bodies requirements for revalidation
and have related it to the practice of aesthetic medicine.
A2.10 The practitioner must evidence written procedure protocols for each of the procedures they
undertake.
A2.11 The practitioner must keep up to date with the law and clinical and ethical guidelines that apply to
their work and must follow the law, our guidance and other regulations relevant to their work. (4)
Standard A4 Confidentiality
A4.1 The practitioner must evidence a written confidentiality policy and demonstrate compliance.
A4.2 The practitioner/clinic must ensure that all staff understand their responsibilities to protect client
confidentiality in compliance with The Data Protection Act 1998, and The Human Rights Act 2005.
A4.3 The practitioner/ clinic must ensure that paper records, wherever held or transported, are stored
securely.
A4.4 Many improper disclosures are unintentional. You should not share identifiable information about
patients where you can be overheard, for example in a public place or in an internet chat forum. You
should not share passwords or leave patients’ records, either on paper or on screen (13) * see also
Standards B3.2 and C5.
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Standard A5 Record Keeping
A5.1 Practitioners must evidence that clinical records are maintained which meet legal regulatory and
professional standards
A5.2 Practitioners must evidence a written policy for record keeping and compliance with the policy.
A5.3 The policy document on Record Keeping must be reviewed and signed annually.
A5.4 Practices must keep log books for:
Adverse Events
Complaints
Procedures
Fridge Temperature Monitoring
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Standard A6 Informed Consent
A6.1 A practitioner/Clinic must have a documented policy or procedure for obtaining consent and
consulting with clients and prospective clients
A6.2 Practitioners must identify and understand the patient’s needs and expectations based on a face to
face consultation.
A6.3 The consent procedure is conducted by the treating clinician
A6.4 Practitioners must provide patients with quality information from the outset, verbally and in writing.
The information must be;
Clear
In user friendly language. Where medical terms are used, an explanation must be included.
Factually correct
Honest
Without bias.
A6.6 The consent process must be conducted face to face by the clinician, on an individual basis with
appropriate privacy.
A6.7 Patients must be given sufficient time to reflect before a decision to consent is made
A6.8 Practitioners must work with each of the patients in their care to ensure the patients expectations of
outcomes can be achieved for them and are realistic.
A6.9 Practitioners must consider the psychological needs of their patients and the risks versus the benefits
of treatment for the individual.
A6.10 Practitioners should not treat patients under the age of 18 except in exceptional circumstances where
the benefits clearly outweigh the risks. If a young person has capacity to decide whether to undergo
an intervention, you should still encourage them to involve their parents in making their decision.
Refer to experts in treating children and young adults when possible. (33)
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Accreditation Assessment Method For Standard A6
Stage 1 Consent to Treatment Policy
Pre- Treatment Specific Consent Forms
Qualification
Have a hard copy file of Consent Policy
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Standard A7 Medicines Management
A7.1 There must be a written policy in place to ensure compliance with legislation and professional
standards for storing, prescribing, administration, record keeping and disposing of medicines and
devices.
A7.2 Practitioners/clinics must evidence supply from an appropriately licensed pharmacy or wholesaler.
A7.3 Practitioners must demonstrate compliance with the written policy for medicines management.
A7.4 Practitioners prescribe drugs or treatment, including repeat prescriptions, only when they have
adequate knowledge of the patient’s health and are satisfied that the drugs or treatment serve the
patient’s needs
A7.4a Nurses/midwives who are not registered independent prescribers must evidence patient specific
directions to administer, signed by the prescriber.
A7.4b Nurses/midwives who are not registered independent prescribers must evidence compliance with a
written policy for administration. The policy must provide details of the prescriber including name,
registration number and evidence of their training in the treatment prescribed.
A7.5 Practitioners must carry out a physical examination of patients before prescribing injectable cosmetic
medicines and must not therefore prescribe these medicines by telephone, video link, online or at the
request of others for patients you have not examined. (11)
A7.6 Practitioners must maintain a procedure log (Standard A5.4) which should record medicines/devices
lot number in a way that allows identification of patients who have been treated with a particular
device or medicine in the event of product safety concerns or regulatory enquiries. (40)
A7.7 Practitioner must only use licensed, approved and recognized products that have been legitimately
sourced via product manufacturers and licensed pharmaceutical suppliers.
A7.8 When using medicines or devices other than for their licensed indications or use as per manufacturer
directions, the patient must be informed as per standards for consent.
A7.9 Practitioners must seek and act on evidence about the effectiveness of the interventions they offer
and use this to improve their performance. (12)
A7.10 Practitioners must provide interventions based on the best available up-to-date evidence about
effectiveness, side effects and other risks. (12)
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Accreditation Assessment Method For Standard A7
Provide delivery note/s to evidence legitimate supply
Stage 1 *Non- Prescribing Nurses/midwives provide statement from Prescriber to confirm compliance
Pre- with Standard
Qualification Medicines Management Policy
Medicines Management Procedure Protocols
Have a hard copy file of Medicines Management Policy
Hard copies of procedure protocols
*Policy for non- prescribing nurses/midwives
* Prescriptions/directions to administer signed by prescriber
Stage 2
Procedure Log Book
Site Visit
Inspection of devices and medicines stored; CE mark, brand, expiry date
Storage complaint with policy
Disposal compliant with policy
Discussion to confirm knowledge of appropriate reporting responsibilities and pathways
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Standard A8 Infection Control
A8.2 The Practitioner/Clinic(s) must demonstrate and evidence appropriate infection control measures
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Standard A9 Adverse Events
A9.1 A Practitioner/Clinic must ensure that emergency first aid treatment is always immediately available
for anaphylactic reactions whenever a treatment is being administered
A9.2 All practitioners must be appropriately trained and regularly update their skills in basic life support
and the treatment of anaphylaxis in line with the latest Resuscitation Council Guidelines.
A9.3 Practitioners must provide evidence of training and protocols for BLS and anaphylaxis and protocols
for pending necrosis
A9.4 All practitioners/premises must have written procedure protocols for identifying and managing
potentially serious or life threatening conditions
A9.5 Practitioners/clinics must report product/medicines safety concerns to; the relevant regulator, the
manufacturer, the insurer and if relevant the patient’s GP.
A9.6 Practitioners must support patients to report adverse events involving medicines or medical devices
to The MHRA. (47)
A9.7 Practitioners must be open and honest with patients when things go wrong and the patient suffers or
may suffer harm or distress as a result. (10)
A9.8 A9.8 Practitioners must provide out of hours contact details for use in an emergency and provide
appropriate follow up care.
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Standard A10 Quality Assurance and Audit
A10.1 A10.1 Practitioners/clinics must take part in systems of quality assurance and quality improvement to
promote patient safety. This includes:
a. taking part in regular reviews and audits of their own work and that of their team, responding
constructively to the outcomes, taking steps to address any problems and carrying out further
training where necessary
b. regularly reflecting on their standards of practice and the care they provide (22)
A10.2 Practitioners must maintain a procedure log which includes notes on patient outcomes to provide an
annual report and audit.
A10.3 Practitioners must seek and act on feedback from patients. (5)
a. Signpost to The Save Face website to provide and record verifiable feedback
b. Address negative feedback constructively and proactively.
c. Use patient feedback and feedback from colleagues to inform practice and improve the quality
of service and care you provide (5)
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Standard A11 Team Working
A11.1 Practitioners must work effectively with healthcare professionals and others involved in providing
care. Practitioners must respect the skills of colleagues within multidisciplinary teams and support
them to deliver good care. (43)
A11.2 Recognize and work within the limits of their competence, seeking advice when necessary
A11.3 Practitioners must consider whether it is necessary to consult the patient’s GP to inform the
discussion about benefits and risks. If so, they must seek the patient’s permission and, if they refuse,
discuss their reasons for doing so and encourage them to allow you to contact their GP. If the patient
is determined not to involve their GP, practitioners must record this in their notes and consider how
this affects the balance of risk and benefit and whether they should go ahead with the intervention.
(27)
A11.4 Practitioners should give patients written information that explains the intervention they have
received in enough detail to enable another (practitioner) to take over the patient’s care. This should
include relevant information about the medicines or devices used. You should also send this
information, with the patient’s consent, to their GP, and any other doctors treating them, if it is likely
to affect their future healthcare. If the patient objects to the information being sent to their doctor,
practitioners must record this in their notes and will be responsible for providing the patient’s follow-
up care. (39)
A11.5 Practitioners must seek advice from colleagues if the patient has a health condition that lies outside
their field of expertise and that may be relevant to the intervention or the patient’s request. (44)
A11.6 Practitioners must build a support network of experienced professional colleagues who can support
and advise. (45)
A11.7 Practitioners must seek to identify any real or potential psychological risk factors when assessing a
patient and support patients to seek expert advice or support. (45)
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Standard B1 Patient and Practitioner Safety
B1.1 Practitioner/Clinic must implement and monitor systems to ensure the general health and safety of
service users, staff and others in accordance with the Health and Safety at Work Act 1974 and the
Control of Substances Hazardous to Health Regulations 2002
B1.2 Practitioner/Clinic must take all reasonable steps to ensure that the facilities are suitable with respect
to design, layout and service to provide clinical procedures.
B1.3 Practitioner/Clinic must ensure that the facilities provided for service users are well maintained
B1.4 Practitioner/Clinic must ensure that medical equipment is safe and appropriate for the services
provided
B1.5 Practitioner/clinic must keep patients safe and comply with statutory reporting responsibilities.
1B.6 Practitioner/Clinic must have systems in place to ensure regular inspection, calibration, maintenance
and replacement of medical equipment to ensure that it is safe to use
B1.7 Where practitioners work peripatetically contracts must be in place to assign responsibilities for
patient records and data, follow up and out of hours' care.
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Standard B2 Infection Control
B21 Practitioner/Clinic must have a written infection control policy. See Standard A8.
B2.2 The Practitioner/Clinic(s) must demonstrate and evidence appropriate infection control measures
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Standard B3 Security
B3.1 The practitioner and staff must ensure policies and protocols are in place to prevent unauthorized
access to confidential documents.
B3.2 The practitioner and staff must ensure policies and protocols are in place to prevent unauthorized
access to;
Medicines
Devices
Equipment
Substances which may cause harm
Valuables
Confidential records
B3.3 Lone workers must have practice policies which recognize and mitigates risks to protect both
patients and staff.
Stage 2 Discussion with practitioners who work alone regarding risks and how they are managed.
Site Visit
See also Standards A4 and A7
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Standard B4 Lighting
B4.1 The treatment room must have lighting of an appropriate quality to perform clinical assessment and
conduct procedures safely.
Stage 2
Inspection to confirm lighting is appropriate
Site Visit
Standard B5 Privacy
B5.1 A Practitioner/Clinic must take all reasonable steps to ensure that the facilities are suitable with
respect to design and layout to ensure service users privacy and dignity.
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Standard C1 Clinic Terms & Conditions
C1.1 Practitioners/Clinics must publish and provide patients with information on terms and conditions of
service. This information should be provided or sign posted at first point of contact.
Stage 2 Site Written copy of Clinic Terms and Conditions available to patients in the clinic
Visit Clinic Terms and Conditions are explained as part of the consent process
C2.2 Practitioners must be open and honest with your patients about any financial or commercial
interests that could be seen to affect the way you prescribe for, advise, treat, refer or commission
services for them. (55)
C2.3 Practitioners must not allow financial or commercial interests in a cosmetic intervention, or an
organization providing cosmetic interventions, to affect recommendations to patients or adherence
to expected good standards of care. (56)
C2.4 You must not mislead about the results you are likely to achieve. You must not falsely claim or
imply that certain results are guaranteed from an intervention. (51)
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Standard C3 Marketing and Communications
C3.1 Practitioners/clinics must comply with the CAP Code, Published by Committee of Advertising
Practice (2013), available here.
C3.2 Practitioners/clinics must Market services responsibly, without making unjustifiable claims about
interventions, trivializing the risks involved, or using promotional tactics that might encourage
people to make ill-considered decisions.
C3.3 Patients will need to have a medical assessment before you can carry out an intervention, your
treatment information and terms and conditions must make this clear. (50)
C3.4 Your marketing must be responsible.
It must not minimize or trivialize the risks of interventions and must not exploit patients’
vulnerability.
You must not claim that interventions are risk free. (49)
C3.5 You must not use promotional tactics in ways that could encourage people to make an ill-
considered decision. (52)
C3.6 You must not provide your services as a prize. (53)
C3.7 You must not knowingly allow others to misrepresent you or offer your services in ways that would
conflict with this guidance. (54)
C3.8 Your marketing activities must not target children or young people through either content, context or
placement. (35)
C3.9 On social media:
Practitioners must not share confidential information about patients
Must not post anything that may be viewed as discriminatory, does not recognize individual
choice or does not preserve the dignity of those in your care.
Practitioners must communicate with colleagues in a respectful way
Practitioners must not use social media to harass, victimize or bully another individual.
Practitioners
Practitioners must declare any conflict of interest, or financial gain when posting about
products or devices.
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Standard C4 Complaints
C4.1 A Practitioner/Clinic must have a written policy for the investigation and management of complaints
and concerns.
C4.2 Practitioner(s)/Clinic(s) must have a written policy and procedure for investigating and managing
complaints about any part of the service/ treatment/ facility. The policy must stipulate how to make
a complaint, who will be responsible for investigating the complaint and the timeframes for
responding.
C4.3 A Practitioner/Clinic must keep a record of all complaints and must take reasonable use complaints
and feedback to improve quality and safety of patient care and experience.
C4.4 A Practitioner/Clinic must ensure that information is readily available to clients to advise them on
how to make a complaint or raise a concern.
C4.5 All staff should be aware of the complaints policy
C4.6 Practitioners/clinics must be compliant with The Consumer Protection Act 2015 and undertake to
sign post to and comply with an appropriate licensed Alternative Disputes Resolution Scheme for
unresolved service complaints
C4.7 Practitioners must provide details of insurance provider when requested by patients or legal
representatives to do so.
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Standard C5 Patient Information
C5.1 A1Practitioners must communicate clearly and respectfully with patients, listening to their questions
and concerns and considering any needs they may have for support to participate effectively in
decision making. (14)
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